A business receiving support payments for Covid-19 needs to ensure the receipt is recorded as taxable income for corporation tax purposes. For unincorporated businesses using the cash basis, this is straightforward enough. But, where the accounts are prepared using GAAP, more care is needed.
Section 106 of Finance Act 2020 states that payments received under the following schemes are within the scope of this:
- the coronavirus job retention scheme;
- the self-employment income support scheme;
- any other scheme that is the subject of a direction given under section 76 of the Coronavirus Act 2020
- the coronavirus statutory sick pay rebate scheme;
- a coronavirus business support grant scheme;
- any scheme described in regulations made under this section by the Treasury.
Schedule 16 then deals with the tax treatment of the income, as well as exemptions for charities, charitable companies and community amateur sports clubs.
In a nutshell
The basic rule is that the payments are taxable when they are recognised using GAAP. This means that they should be reported in the period they relate to, rather than when they are received. This is based on the date that the business becomes entitled to the payment, not the date it is paid. The first tranche of LA grants based on the business premises’ rateable value was approved on 11 March 2020. Based on the RV at that date, as long as the business was still trading. There were no performance conditions, so an eligible business became entitled to the grant on 11 March 2020. This is the correct date to use for recognising the income.
But, there are some important exceptions to this general rule.
- Receipts under the Self-Employed Income Support Scheme are taxable in 2021, even if part of this is because of the period before 6 April 2020.
- If a business ceases trading but receives a coronavirus support payment, the income is included for the year it is received, even if this gives a different result than under GAAP